Free Motion for Extension of Time - District Court of Connecticut - Connecticut

Case 3:03-cv-01036-DJS

Document 60

Filed 02/02/2005

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT _______________________________________ CALL CENTER TECHNOLOGIES, : : Plaintiff, : : v. : : GRAND ADVENTURES TOUR & : TRAVEL PUBLISHING CORPORATION, : INTERLINE TRAVEL & TOUR, INC. : : Defendants. :
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CIVIL ACTION NO. 3:03CV1036 (SRU)

JANUARY 31, 2005

DEFENDANT INTERLINE TRAVEL & TOUR INC.'S MOTION FOR EXTENSION OF TIME AND MOTION TO MODIFY THE STANDING ORDER Interline Travel & Tour, Inc. ("Interline"), a defendant in the above-captioned matter, respectfully requests a fifteen (11) day extension of time (until February 11, 2005) to disclose any expert witness(es) in this case. This is an alleged breach of contract action in which the plaintiff, Call Center Technologies, Inc. ("CCTI"), claims that Interline is somehow obligated to compensate the plaintiff for certain parts and equipment provided to co-defendant, Grand Adventures Tour & Travel Publishing NO ORAL ARGUMENT REQUESTED/ TESTIMONY NOT REQUIRED

Case 3:03-cv-01036-DJS

Document 60

Filed 02/02/2005

Page 2 of 5

Corporation ("GATT"). The gravaman of the plaintiff's complaint against Interline is that Interline is a successor in interest to GATT and should therefore be liable for the alleged debts of GATT. Interline has denied the substantive allegations of the Plaintiff's Second Amended Complaint. On December 7, 2005, the Court amended the original Standing Order of the parties (dated September 24, 2003) and ordered that the parties to disclose expert witnesses by January 15, 2005. On January 18, 2005, the undersigned with consent of plaintiff's counsel moved to extend the discovery deadline to today. The Court issued an order indicating that "Responses" were due February 1, 2005. The undersigned makes this motion under the exercise of caution in case the discovery deadline has not been extended to February 11, 2005 and to have additional time to confer with her client. This is Interline's second request to seek an extension of time of the Court's December 7, 2004 discovery deadlines. The requested extension will not delay the proceedings in this case as the deadline for deposing any of Interline's expert witnesses is April 1, 2005. The undersigned contacted plaintiff's counsel, Joel Shafferman, on January 26, 2005 and January 28, 2005 to advise him of the instant motion but did not receive a response from him as to his position with respect to it at the time of the writing of this motion. WHEREFORE, Interline respectfully requests that its Motion for Extension of Time be granted and that the Court's Standing Order be modified accordingly.

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Case 3:03-cv-01036-DJS

Document 60

Filed 02/02/2005

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Respectfully submitted, DEFENDANT, INTERLINE TRAVEL & TOUR, INC. By:_________________________ LAURA F. BALDINI, ESQ. Federal Bar Number ct19887 Law Offices Of Laura Flynn Baldini, LLC 2 Batterson Park Road, 2nd Floor Farmington, CT 06032 Tel. (860) 874-8483 Fax. (860) 561-9823 [email protected] Juris. No. 421267

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Case 3:03-cv-01036-DJS

Document 60

Filed 02/02/2005

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ORDER The foregoing MOTION, having been duly presented to this Court, it is hereby ORDERED, that the same be and hereby is GRANTED/DENIED. THE COURT,

___________________________ JUDGE/Clerk

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Case 3:03-cv-01036-DJS

Document 60

Filed 02/02/2005

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CERTIFICATE OF SERVICE I HEREBY CERTIFY that I caused a copy of the foregoing to be served on this 31st day of January, 2005 upon the following by first-class United States Mail, postage prepaid: Joel Shafferman, Esq. Solomon, Pearl, Blum, Heymann & Stich, LLP Counsel for Plaintiff 40 Wall Street, 35th Floor New York, NY 10005 And to: Clerk's Office United States District Court 450 Main Street Hartford, CT 06103

By:_______________________________ LAURA F. BALDINI, ESQ. Law Offices of Laura Flynn Baldini, LLC

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